Legal Notice

This privacy notice describes the collection and further processing of personal data by Josephine Leroy companies. If the activities covered by this notice fall within the scope of other privacy policies, are manifestly circumscribed or are subject to applicable laws outside Switzerland and the EU, such applicable laws and policies shall prevail. The term 'personal data' covers all information relating to an identified or identifiable person.

This Privacy Notice describes in Section 1, the processing of personal data by Josephine Leroy in general. Section 2 contains specific provisions for specific applications (e.g. for online shops or newsletter and banner advertising).

If you provide Josephine Leroy with the personal information of others, such as the recipient of a gift, please provide that personal information to Josephine Leroy only if you are authorized to do so under applicable data protection laws and only if the other person agrees that you may provide Josephine Leroy with their personal information for the purposes for which the information is collected and that such personal information will be processed in accordance with our Privacy Notice.

I. General provisions

1. Processing of personal data

For each website (including the online shop websites), each social media presence, multimedia portals and chatbots, and each Josephine Leroy application (each referred to as a website), Josephine Leroy has a data controller in respect of the collection of personal data under the Swiss Data Protection Ordinance (or equivalent provisions of relevant data protection laws). Insofar as the corresponding website (imprint, terms of use, etc.) or the following sections 2 and 3 do not contain any other provisions, Josephine Leroy, P.O. Box 471, 8965 Berikon AG, Switzerland, is responsible for the online shops www.josephine-leroy.com.

If Josephine Leroy communicates via other means of communication (such as e-mail, letter, telephone or in person) and this communication cannot be assigned to any activity for which Josephine Leroy has designated a responsible person in this data protection notice or in any other way, the respective subsidiary or affiliated company shall act as the responsible person.

If a Josephine Leroy or an affiliate discloses personal information to another Josephine Leroy entity for a particular purpose of the receiving company or affiliate, the respective company or affiliate is responsible.

How to reach Josephine Leroy:

If you wish to exercise your rights regarding newsletter subscriptions, data access or data deletion, please do not hesitate to contact us via info@josephine-leroy.com, we will be happy to answer your questions.
Questions, requests, or concerns regarding Josephine Leroy's privacy policy may also be directed to info@josephine-leroy.com .

If you provide Josephine Leroy with the personal information of others, such as the recipient of a gift, please provide such personal information to Josephine Leroy only if you are authorized to do so under applicable data protection laws and only if such other person agrees to provide Josephine Leroy with their personal information for the purposes for which the information is collected and that such personal information will be processed in accordance with our Privacy Notice.


2. Processing of personal data

Josephine Leroy collects and processes personal data of

  • Users of the registered websites of Josephine Leroy;
  • Users who are registered on a Josephine Leroy website (for example, if they have set up a user account);
  • Persons who purchase, receive or benefit from Josephine Leroy products or services;
  • Potential or actual purchasers of Josephine Leroy's products or services;
  • Recipients of Josephine Leroy newsletters;
  • Participants in research campaigns and opinion polls conducted by Josephine Leroy;
  • Participants in Josephine Leroy's courses, seminars and other training;
  • Users using the WIFI access provided by Josephine Leroy in stores (coming later) or other locations;
  • Customers registered for the Loyalty Program or persons purchasing through or using Josephine Leroy's Loyalty Program.


(collectively referred to as Customer)

The personal data of customers is generally collected by Josephine Leroy during the use of the website, in the shops and at events of Josephine Leroy as well as during direct communication such as by e-mail, telephone or in any other way directly by Josephine Leroy. Personal data may also be collected indirectly, for example through external contract processors (e.g., Josephine Leroy partners (as defined below, which includes wholesalers, specialty retailers, retailers, suppliers and other business partners and customer service providers)). Josephine Leroy also collects data if the customer making the purchase is not the same as the person benefiting from the purchase, if the purchased goods are sent to another person (e.g. as a gift), if the purchase is based on the recommendation of a third party (e.g. the recommendation of family members or friends of the customer) or by further obtaining supplementary information from third party sources (e.g. social media).

Josephine Leroy processes the following categories of personal data, among others:

  • Personal data and contact information, including, but not limited to, first and last name, birth name, address, residence, telephone number, e-mail address, date of birth, gender, marital status, relatives, emergency contact, pictures;
  • Data relating to orders and purchases, including but not limited to payment information, credit card information and other payment details (in accordance with other laws and regulations), billing and shipping information, information about products and services ordered and purchased, information, inquiries and complaints relating to products and services, contracts entered into, for example relating to warranty claims, after-sales service, repairs, customer care and after-sales services, as well as cancellation, cancellation and other disputes;
  • Data related to the marketing of products or services, including, but not limited to, information related to newsletters or other communication channels, subscriptions and unsubscriptions, invitations to and participation in events and special activities (other than as part of the Customer Loyalty Program), personal preferences and interests, and information about customer segmentation;
  • Data related to use of the Site, including but not limited to IP address and other user ID (e.g., social media username, MAC address of smartphones or computers, cookies), date and time of visits to the WEBSITE, pages visited and content, and referring Web sites;
  • Data relating to communication, including, but not limited to, preferred means of communication, correspondence and communication with Josephine Leroy (including communication records);
  • Data collected in connection with a Customer Program, including, but not limited to, membership numbers, access codes (including passwords), preferred language, number of gift certificates, date and duration of membership, payment information of the Customer or any third party, information about the recipient of a gift, Number of visits to the Site, purchase history, products purchased (all Site accounts, activities and events for which a Customer must register with his/her personal information in order to enter into a contract with Josephine Leroy shall be deemed to be a Customer Program for the purposes of this Policy, other than traditional Customer Loyalty Programs);

(collectively referred to as Customer Data)

  • Data from users of the Site who do not register with Josephine Leroy (Guest) when it is personal data, such as social media. The provisions contained in this notice regarding the collection of information from a customer in connection with that customer's use of the Site shall apply mutatis mutandis, even though Josephine Leroy may not normally be able to identify a Guest;
  • Information about employees and other persons who work for Josephine Leroy wholesalers, retailers, retailers, suppliers or other business partners of Josephine Leroy (natural persons hereinafter referred to as partners and their data as partner data), such as contact details, information about the function of the person concerned, information about previous contacts with the person concerned, information about marketing activities (e.g. receipt of newsletters), information about business transactions, requirements, offers, invitations to tender, terms and conditions and contracts, and information about the professional or other interests of the persons concerned.

The customer is obliged, within the framework of his business relationship, to provide the data required for the establishment and performance of the contractual relationship and the fulfilment of the associated contractual obligations or to provide such data within the scope of his business relationship.

3. Purpose of processing and legal basis

3.1. Purpose of processing

In accordance with applicable law, Josephine Leroy may process customer data for legitimate purposes. This includes, but is not limited to, the following purposes:

  • In connection with offering services, concluding contracts (e.g., purchase contracts), performing contracts (e.g., purchase contracts or contracts for participation in customer programs or events), maintaining or developing customer relationships, communications, customer service and support, sales, advertising, and marketing promotions (including newsletters and promotional materials).
  • Organizing users of the Site and other activities in which customers participate, operating and improving the Site (including providing features that require identifiers or other personal information), setting up additional IT systems, or performing identity checks;
  • Protect customers, employees and others; protect data, trade secrets and assets belonging to or entrusted to Josephine Leroy; and protect Josephine Leroy's systems and premises;
  • Complying with legal and regulatory requirements and Josephine Leroy's internal policies, enforcing and enforcing legal rights and claims, defending against legal claims, litigation, complaints, combating abusive conduct, participating in judicial investigations and proceedings, and responding to government requests;
  • Sale or purchase of business units, companies or interests in companies and other corporate transactions, as well as transmission of related customer data, and other lawful purposes, if the processing arises from the circumstances or was disclosed at the time of data collection.

(collectively referred to as the purpose of processing Customer Data)

3.2. Legal basis for processing

Josephine Leroy bases its use of customer data for the purpose of processing customer data on the following legal principles:

  • Performance of contracts;
  • Josephine Leroy's compliance with legal obligations;
  • The customer's consent (only if the processing is based on a specific request and can be withdrawn at any time, for example in relation to the receipt of newsletters for which the customer has registered);
  • Josephine Leroy's legitimate interests, including but not limited to
  • Purchase and shipment of products and services, including in relation to persons who are not direct contractors (e.g. persons receiving a gift);
  • Advertising and marketing activities;
  • Efficient and effective customer support, contact management and other communications with customers, other than the processing of contracts;
  • Understand customer behavior, activities, concerns and needs, and market studies;
  • Efficiently and effectively improve existing and develop new products and services;
  • Efficiently and effectively protect customers, employees, and others, as well as data, trade secrets, and assets belonging to or entrusted to Josephine Leroy, and the systems and premises of Josephine Leroy;
  • Maintaining and maintaining the safe, efficient and effective organization of business operations, including the safe, efficient and effective operation and successful development of Web sites and other IT systems;
  • Appropriate corporate governance and corporate development;
  • Successful sale or purchase of business units, companies or interests in companies and other corporate transactions;
  • Compliance with legal and regulatory requirements and with Josephine Leroy's internal regulations;
  • Concerns regarding the prevention of, and investigation into, fraud, crimes and crimes related to such crimes or other improper conduct, the handling of claims and actions brought against Josephine Leroy, cooperation in legal proceedings and with authorities, and the prosecution, exercise and defense of claims.

Subject to applicable privacy laws, Josephine Leroy may process guest information for the purpose of maintaining and developing the Site (including providing features that require identifiers or other personal information), statistically evaluating your use of the Site, combating abusive conduct, investigating or proceeding, and responding to governmental requests. The guest data shall be processed in accordance with the principles set out above for customer data.

Subject to applicable data protection laws, Josephine Leroy may use partner information for the purpose of entering into and performing contracts and other business relationships with partners, for sales, advertising and marketing promotions, communications, invitations to events and participation in sales promotions for partners, organizing joint activities, meeting legal and regulatory requirements, and complying with Josephine Leroy's internal regulations, Enforce and enforce legal rights and claims, defend legal claims, litigate, complain, combat abusive conduct, participate in judicial investigations and proceedings and respond to governmental requests, sell or acquire business units, companies or interests in companies and other corporate transactions and for the transfer of related partner data. The Partner Data shall be processed in accordance with the principles set out above for Customer Data. All processing purposes apply to the entire Josephine Leroy, not just the company that originally collected the personal data. Personal data of customers, guests and partners will be collected in accordance with this Privacy Notice, all other policies issued by Josephine Leroy and applicable data protection laws.

4. Transmission and disclosure of data

In accordance with applicable data protection laws, Josephine Leroy may transfer customer data, guest data and partner data to the following categories of third parties who process personal data on behalf of Josephine Leroy or for their own purposes in accordance with the purpose of the data processing:

  • Service providers (within Josephine Leroy and external), including contract processors;
  • Wholesalers, specialist dealers, retailers, suppliers and other business partners;
  • Customers of Josephine Leroy;
  • Local, national and foreign authorities;
  • Media;
  • The public, including visitors to Josephine Leroy's Web sites and social media;
  • Industrial organizations, associations, organizations and other committees;
  • Acquirers or prospective purchasers of business units, companies or other interests in Josephine Leroy;
  • Other parties in potential or actual legal proceedings;
  • Other companies of Josephine Leroy.

(collectively referred to as third parties)

Josephine Leroy may disclose customer data, guest data and partner data within Josephine Leroy and to third parties in any country worldwide, including but not limited to any country in which Josephine Leroy is present through companies, affiliates or other branches or agents, and in countries where Josephine Leroy service providers process their data. If data is disclosed to countries that do not provide adequate protection, Josephine Leroy itself will protect the data disclosed to customers, guests or partners by providing appropriate contractual guarantees (e.g. based on Switzerland and the EU standard clauses), binding corporate regulations, based on the data protection shield framework existing between Switzerland, the EU and the USA and between Switzerland and the USA for the transfer of data to third parties resident in the USA or the transfer of data on the basis of consent, for the conclusion or performance of contracts or in connection with the establishment, exercise or enforcement of legal claims or on the grounds of overriding public interests or for the protection of the integrity of the persons concerned. The relevant customer, guest or partner may obtain copies of the contractual warranties from the above contact points or learn where such copies are available. Josephine Leroy reserves the right to process such copies for legal or confidentiality reasons.

5. Data storage

In principle, Josephine Leroy does not store personal data for longer than is necessary for the purposes for which it is processed. Notwithstanding this general principle, Josephine Leroy may process personal data for extended periods of time in accordance with the following rules and obligations: Josephine Leroy will retain personal data for as long as Josephine Leroy (i) is required to do so (by contract, law, or other regulation) or (ii) has a primary interest in such data (e.g., an interest in providing evidence of claims, documenting compliance with certain legal or other requirements, or an interest in a non-personal analysis). We reserve the right to deviate from the provisions of applicable law regarding the anonymization or anonymization of personal data.

For contract-related customer and partner data (including business documents and communication), Josephine Leroy shall store personal data for as long as the contractual relationship exists and for a period of ten years after termination of the contractual relationship, unless (i) in individual cases there is a shorter or longer statutory storage obligation, (ii) the storage is not necessary for reasons of proof or for any other reason permissible under applicable law, or (iii) the deletion of the data is not necessary earlier (for example, because the data is no longer required or because Josephine Leroy is obligated to delete the corresponding data). 

In the case of operating data containing customer data, guest data or partner data (e.g. logs), Josephine Leroy will generally store personal data for a period of 3-12 months.

6. Cookies, Google analytics and social Plugins

Josephine Leroy uses cookies on its websites, a widely used technology whereby the user's browser is assigned an identifier to a website which the user stores and displays on request. First, Josephine Leroy uses session cookies, which are automatically deleted when the user closes the Web site. These cookies enable the server to establish a stable connection with the user (e.g. so that the contents of a shopping cart are not lost) while the user is surfing the website. On the other hand, Josephine Leroy also uses permanent cookies, which are only deleted after a time defined for the website. Permanent cookies allow certain settings (e.g. language) to be saved for several sessions or an automatic login. By using the website and the corresponding functions (e.g. language settings and automatic logins), the user consents to the use of permanent cookies. The User may block or delete the use of cookies in his/her browser, but this may affect the use of the Websites.

To the extent permitted by applicable law, Josephine Leroy may include in its newsletters and other marketing communications an encoding to determine whether the recipient has opened an email or downloaded images contained in the email. The recipient can, however, block this application in his e-mail settings. By receiving newsletters or other marketing e-mails, the recipient agrees to the use of this technology in any case.
automatic login. By using the website and the corresponding functions (e.g. language settings and automatic logins), the user consents to the use of permanent cookies. The User may block or delete the use of cookies in his/her browser, but this may affect the use of the Websites.

To the extent permitted by applicable law, Josephine Leroy may include in its newsletters and other marketing communications an encoding to determine whether the recipient has opened an email or downloaded images contained in the email. The recipient can, however, block this application in his e-mail settings. By receiving newsletters or other marketing e-mails, the recipient agrees to the use of this technology in any case.
Josephine Leroy may use Google Analytics or similar services on its website. These applications are third-party services that allow Josephine Leroy to measure and analyze the use of its website. The provider of these services may be located in any country in the world (in the case of the Google Analytics service operated by Google Inc., this means the United States, www.google.com). The service provider uses permanent cookies for these applications.

Josephine Leroy does not disclose any personal information to the Service Provider (which does not store IP addresses). However, the Service Provider may monitor the User's use of the Website and combine this information with information from other websites monitored by the same Service Provider and visited by the User. The results may be used by the Service Provider for its own benefit (e.g. to control advertising). The Service Provider knows the identity of the User who has registered with the Service Provider. In this case, the Service Provider is responsible for the processing of personal data, which must comply with data protection regulations and the laws protecting personal rights as well as the Service Provider's data protection guidelines (see policies.google.com/privacy with regard to Google).  The Service Provider will provide Josephine Leroy with information about the use of the Website.

In addition, Josephine Leroy may use on its Website plug-ins from social media networks such as Facebook, Twitter, Youtube, Google+, Pinterest or Instagram. The plug-ins are deactivated by default on the website, but the user has the option of activating them. If the user activates them, social media providers are able to establish a direct connection with the user during the user's visit to the website. This enables the providers to register the user's visit and analyse the relevant information. The subsequent processing of personal data is the responsibility of the respective social media providers in accordance with the data protection regulations and laws for the protection of personal rights and the data protection guidelines published on their websites (for example www.facebook.com/; www.twitter.com/; www.youtube.com/; www.google.com/; www.pinterest.com/; www.instagram.com/).

For more information about the co-products default on the website, but the user has the option of activating them. If the user activates them, social media providers are able to establish a direct connection with the user during the user's visit to the website. This enables the providers to register the user's visit and analyse the relevant information. The subsequent processing of personal data is the responsibility of the respective social media providers in accordance with the data protection regulations and laws for the protection of personal rights and the data protection guidelines published on their websites (for example www.facebook.com/; www.twitter.com/; www.youtube.com/; www.google.com/; www.pinterest.com/; www.instagram.com/).

For more information about the co-products used by Josephine Leroy, please contact.

7. Rights of customers, guests and partners

All data subjects, including all customers, guests and partners, may request information from Josephine Leroy as to whether data concerning them will be processed. In addition, they have the right to request the rectification, destruction or limitation of personal data concerning them or to object to the processing of personal data. If the processing of personal data is based on consent, the data subject may withdraw such consent at any time. In EU and EEA countries, data subjects have the right in certain cases to request data generated during the use of online services in a structured, common, machinereadable format that allows further use and transmission. Please address such requests to the contact points. Josephine Leroy reserves the right to limit the rights of data subjects in accordance with applicable laws and, for example, not to disclose extensive information or delete data. 

If Josephine Leroy makes an automated decision with respect to a particular individual that has a legal effect on that individual or similarly seriously affects that individual, the individual has the right, in accordance with applicable law, to contact a Josephine Leroy officer and request a review of the decision or the reasons for the prior decision by that officer. In this case, the data subject may no longer be able to use certain automated services. The person concerned will then be informed of this in advance or in a separate notification.

Any data subject may also lodge a complaint with the competent data protection authority. In the case of a person responsible for Josephine Leroy in Switzerland, this is the Swiss Office of the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch); in the case of a person responsible for Josephine Leroy in the Principality of Liechtenstein, this is the Office of the Data Protection Commissioner in the Principality of Liechtenstein (https://www.llv.li/).

8. Change of the data protection notice

Josephine Leroy reserves the right to change this Privacy Notice at any time without notice. The most recent version published on the Josephine Leroy website shall apply.

If the Privacy Notice is part of an agreement with a customer or partner, Josephine Leroy may notify that customer or partner by e-mail or other appropriate means of any update or change. The changes shall be deemed to have been accepted unless an objection is lodged within 30 days of receipt of the notification. In the event of an objection, Josephine Leroy is free to terminate the agreement without notice.

II. Special provisions

The following provisions supplement the general provisions in Section I relating to certain activities of Josephine Leroy. In the event of any discrepancy, the following provisions shall prevail.

1. Online - Shops

In online shops, the creditworthiness of customers can be assessed automatically in order to be able to offer a prepay/invoice purchase on the basis of this decision. In this case, creditworthiness is assessed on the basis of information provided by an external credit rating agency, which provides Josephine Leroy with a credit rating for the respective customer. The agency calculates this rating using a secret formula based on data from the customer's payment history, debt and insolvency history, and any restrictions on the customer's ability to do business. If the rating is below a certain threshold, no prepayment purchase with invoice will be offered. If the customer is not prepared to accept this decision, he can contact the contact person named in the imprint of the corresponding website of the online shop.

Josephine Leroy's online shop may automatically decide whether to conclude a sales contract. However, Josephine Leroy does not regard this as an automated decision in an individual case. If the customer does not wish to have such an automated contract concluded, he has the option of purchasing the products and services with advance payment.

2. Partners, including wholesalers, retailers, specialist dealers, service providers, etc.

As already mentioned, Josephine Leroy collects customer data, partner data and guest data directly, but also indirectly (e.g. when Josephine Leroy commissions third parties, such as Josephine Leroy's partners, as processors). In such cases, Josephine Leroy's partners process the personal data on behalf of and in accordance with Josephine Leroy's instructions. They are bound by special processing agreements in which their obligations are regulated in such a way that the protection of the rights of our customers as well as the processing and protection of their personal data is guaranteed in accordance with the applicable data protection laws.


3. Newsletter and banner advertising

osephine Leroy may send newsletters and other commercial communications to customers and partners in connection with its products and services. To the extent permitted by applicable law, Josephine Leroy reserves the right to send such newsletters without the prior consent of existing customers and business partners. However, the customers and business partners concerned may at any time refuse to receive further newsletters or other commercial communications via their account on the relevant website or via the link included in each delivery. However, the termination of a newsletter does not necessarily extend to other newsletters.

Josephine Leroy reserves the right to place personalised advertisements during visits to the Website. Such banner advertising presented to the customer shall contain the products offered on the website which the customer has previously viewed. Josephine Leroy generates this advertising using cookies (see Section 6 in Section I above).

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